Martyn Williams: Response to Road Safety Framework annual report

KJIPUKTUK (Halifax) – The following letter has been sent to members of the Halifax Transportation Standing Committee who are discussing the annual road safety framework report today at 1pm. If you support any or all of the recommendations please contact your councillor, at any time.

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Dear staff and Councillors,

Road Safety in Halifax remains a significant concern for everyone following the recent deaths of a five year old child and an elderly woman. Doctor Gass died and a woman lost two babies she was carrying this year following severe incidents on dangerous crosswalks, in all cases lacking crucial pedestrian safety infrastructure. 

The municipality is not experiencing a traffic flow or congestion crisis. It is experiencing a road safety crisis that is disproportionately affecting people who are most vulnerable.

The annual information report is an opportunity to reflect, review and consider if the clear approach and action requirements set out in the Road Safety Framework are being met.

Per capita fatality rate: Is Halifax progressing towards zero traffic fatalities? 

The overall number of road fatalities per 100,000 population during recent years with usual levels of traffic is very high (average of 17.5 fatalities over 2018 and 2019 or 4.02 per 100,000) – almost double the per capita fatalities for Toronto and Vancouver assessed from 2013 to 2015.

The critical objectives of Vision Zero are to achieve lower numbers of serious injuries and deaths through strategic interventions on the statistically most dangerous streets and intersections, and through a continuous commitment to equity. This requires focus on road users who are disproportionately harmed and killed by traffic crashes.

The number, location and causes of recent fatalities warrants a review of efforts to date against the remit of the road safety framework and what effective Vision Zero strategy requires.

Senior road users (over 55 years old) comprise all pedestrian fatality victims

The senior age of all ten recent pedestrian fatalities in Halifax since 2018 flags the significant safety crisis for seniors, requiring special consideration and focus.

Assessment of safety is required from the perspective of the assessed abilities and capacity of vulnerable road users who are disadvantaged due to age, disability, or both. 

This assessment cannot be completed by traffic staff alone as the process would require input from the skills and experience of someone with expertise in how the aging process affects human behaviour and physical ability. 

Road safety decision-making has not changed

The road safety framework related actions and interventions rely on traffic staff decision-making and control, exactly as it did prior to the approval of the framework. 

There remains lack of clarity and scrutiny due to the absence of the action plans and efforts driven by public and agency/stakeholder involvement, both of which were identified as crucial development requirements within the road safety framework itself.

Key locations where there are concentrations of vulnerable road user incidents, such as intersections along artery roads (such as Robie, Joseph Howe,  Mumford, Quinpool) are not being adapted appropriately to eliminate dangerous conflicts between vehicles and vulnerable road users. 

Both staff and leadership should review Edmonton’s current Safe Mobility Strategy to understand better how Vision Zero planning and action could work:

• Equity as a core and ongoing component of decision-making and actions,
• Clear identification of who is most affected by unsafe streets and how the safety needs of those users will lead priority actions;
• Mapping of High Injury Network(s);
• Key short term actions including proactive safety reviews to understand why incidents are occurring more in specific areas to specific categories of persons, and how that impacts lives.

Key unmet action requirements in the Road Safety Framework

1. Develop the required action plans specific to pedestrians (and intersections)

Due to the lack of collision data analysis at the time, the Road Safety Framework was not intended to be a stand-alone complete plan:

“The development of action plans will be an ongoing process to ensure the effectiveness of specific actions in collision reduction in HRM.” (page 14)

As confirmed recently by staff, the critical pedestrian safety action plan has not yet been developed:

“Develop action plan for worst 10 types of (pedestrian) collisions. Consider rates/frequencies, consistency of collision patterns and crosswalk specific assessments.” – Attachment D, Future Countermeasures, page 6 of 8.

This plan must be developed in conjunction with people who rely upon walking or disability mobility aids for practical mobility, especially those who have physical and learning disabilities or are disadvantaged through age: “Working with different communities, understanding their needs and facilitating open communications is critical to inclusive outreach programs.” (page 14) 

2. The Road Safety Team must include all stakeholders. 

The road safety framework (Attachment D, page 1 of 8) provides for the immediate creation of a Road Safety Team, comprised of  “All participating agencies…and all other stakeholders primarily committed to greater safety for all road users” (own emphasis added) which should “more effectively deliver current programs, develop safety branding and develop safety culture. Team will then be in place and ready to take on action items of SRSP when data becomes available.”

This team should; “develop  actions, lead and ensure implementation, secure funds, measure effectiveness (output and outcomes) at pre‐established timelines, modify and adapt  action plan to meet the goal and objectives, be responsive and responsible, collaborate with all partners,  be the voice of the vision and traffic safety culture in the Region ‐ a role model to others. Need to appoint Chair, Secretary, Coordinator, and person responsible for ambassadors.”

Key stakeholders, especially non-government groups representing active mobility users have not been involved in the strategic development of actions and are not included within the Road Safety Steering Committee. “Advocates” are mentioned in Steering Committee minutes but are not directly involved. 

Since the road safety strategy consultation process in 2018, key community groups and disabled road users have remained sidelined and have relied on uninvited written or oral representations for input on their safety requirements. This is very far from ideal due to time limits for public presentations and the absence of two-way dialogue. The lack of involvement ends in acrimony and severe disadvantage for people who should be the Municipality’s focus for change. 

B. Specific feedback and recommendations on the annual road safety report

3. Early conclusions on the effectiveness of action to date should not be made on 2020 incident data.

“We have seen a drop in the total number of fatal and injury collisions occurring in the region” (road safety update, page 3)

The data available indicates significant drops are likely related to lockdowns and working from home trends. Toronto for example has seen pedestrian fatalities almost halved from the average number of fatalities over the three previous years from 39 to 21. Traffic deaths across Canada dropped by 34 per cent during the beginning of the COVID-19 pandemic.

4. Urgent adaptations at intersections remain critical 

“Nearly 75% of the collisions involving pedestrians occurred at intersections. Most fatal and injury collisions involving pedestrians occur within the Regional Centre where there are increased volumes of both pedestrians and motorists” (update, page 4)

The very high proportion of incidents at intersections is alarming yet not at all surprising given historical data and the fact many intersections are wide and have no safety infrastructure or adaptations that enable a safe crossing for vulnerable road users, for example by preventing vehicle/pedestrian conflicts with appropriate traffic signals.

Currently the use of signalized intersections by pedestrians is a dangerous stunt requiring careful sighting of moving traffic from multiple directions, as depicted in Nova Scotia safety literature.

A pedestrian safety action plan should identify simple and inexpensive adaptations that can be deployed widely, such as the use of poles/bollards for uncontrolled intersections and protected signal phasing for controlled intersections. 

Intersection adaptations should jointly consider and address both pedestrian and cyclist safety such as bump-out bollard positions that allow cyclists to filter through and not around bump-outs, and traffic signal phasing that provides a protected phase for both cyclists and pedestrians at the same time. 

As for previous pedestrian safety reports prior to the road safety framework, staff should ascertain which location/control types are responsible for most incidents and which turning movements result in most endangerment. 

The absence of strategic efforts led by High Injury network mapping is concerning in the context of the municipality’s clear endorsement of Vision Zero methodology. For example, incident data shows Robie Street intersections are very dangerous for pedestrians (a recent incident occurred last night) therefore focused effort on Robie is required to achieve protected signal phases and safer intersections for vulnerable road users. 

Have councillors seen high injury network mapping from staff, like this one presented to the Transportation Standing Committee in May? 

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Combining vehicle and pedestrian movements within a wide multiple lane intersection is extraordinarily dangerous for pedestrians, hence why many jurisdictions especially outside North America (and some within Canada) prevent this through appropriate traffic signal controls.

The wider signalized intersection locations are where recent fatalities and serious injuries are mainly occurring, not at two lane signalized intersections.

Two fatalities and a life threatening injury have occured due to turning drivers striking pedestrians crossing legally at wide signalized intersections within a recent 12 month period. 

This requires special consideration and urgent action.

The currently legal in Nova Scotia straight-on only directional lights, standard choice for suburban signalized intersections in other jurisdictions including the UK, can be used to avoid vehicle/pedestrian conflicts yet still achieve traffic flow through the intersection while pedestrians cross and within the “concurrent phasing” methodology used. 

Given recent fatalities and clear guidance from the Institute of Transportation Engineers that “Vulnerable road user safety must be prioritized over vehicle movement in the selection of traffic control devices”, immediate implementation of directional traffic controls that prevent vehicle/pedestrian conflicts is required to prevent further serious injury or death.

Please also refer to this report for information and research on how protected signal phasing does not prevent transportation efficacy, also extensive guidance on the absolute safety requirement to separate vehicle and pedestrian movements at wider signalized intersections.

5. Planned Engineering Countermeasures for 2021/2022 (Table 5)

It is not clear how the countermeasures were chosen and by whom, and what specific data has been used to select those countermeasures, their deployment and their deemed effectiveness. 

To what extent was the collaborative all-stakeholder approach to decision-making set out in the Road Safety Framework used to choose these interventions?

Extensive recent US-wide city data analysis by the US Federal Highways Agency concluded Leading Pedestrian Intervals result in a 13% reduction in pedestrian incidents. How is this deemed to be sufficient, given the alarming extent of incidents caused by vehicle/pedestrian conflicts at signalized intersections throughout the Municipality, as set out in this analysis from several years of local incident data?

Incident data reveals that intersections where Leading Pedestrian Intervals have been installed continue to experience pedestrian incidents. Has this data and the causes of incidents been reviewed? If incidents due to drivers turning into the path of pedestrians crossing legally have continued, how and why has this particular countermeasure deemed to be effective versus other signal options, including a pedestrian-initiated all-way red phase, or directional signals? 

6. Restricting right on red permissions

Despite clear guidance from multiple agencies responsible for issuing traffic safety guidance that right on reds are extremely dangerous, the development of far wider and very necessary restriction of right on reds is not mentioned. 

7. Lower speed limits where there is most need.

Cities are moving towards adopting 30 km/h speed limits on all urban roads where traffic and people mix, in accordance with the research-based recommendations from the United Nations and the World Health Organisation. This reduces emissions, increases safety and does not (as commonly understood) substantially increase car journey time.

The priority for lower speeds is where data demonstrates incidents are most frequent and severe. In Halifax, that would be in Downtown areas and along artery roads and intersections.

8. Community Engagement

“Community engagement was not undertaken as part of this report as there are ongoing engagement initiatives with the public through education campaigns and enforcement programs” (page 13)

The current approach reflects the historical “Heads Up Halifax” approach of one-directional instructions from staff to road users instead of the two way involvement, participation and equity approach set out within the Road Safety Framework and Vision Zero. 

The report does not mention the involvement and contribution of key stakeholders and road safety providers including the Crosswalk Safety Society of Nova Scotia, Walk n Roll, Ecology Action and Halifax Cycling Coalition. What are these critical stakeholders doing? How are their efforts assessed to be contributing towards the joint aims identified in the strategy?

9. Education

Current campaigns sometimes support common road user misunderstandings on key legal requirements, for example relating to yielding requirements at signalized intersections and are not effective, using website links with a long list of instructions listed as bullet points.

On the change from “Shared Responsibility” to “Everyone’s Responsibility”: Which non-government stakeholders representing road users were consulted on this? 

How is this message deemed to consider seniors, people with disabilities and children, all of whom are least able to avoid and survive inattentive and dangerous driving? What aspects of their “responsibility” are they assessed to be not exercising adequately, based on police incident data and their known cognitive and physical abilities? 

Did staff develop this message with local police, who target driver offences and behaviour in their vulnerable road user safety messaging?

The primary responsibility for road safety rests upon categories of road users who cause most harm to others and commit most offences that result in injury and death to road users. Specifically relating to vulnerable road user safety those offences are distracted driving, driving under the influence, speeding, aggressive and dangerous driving, and failure to yield to pedestrians lawfully using crosswalks.

Without clear messaging targeting specific behaviours and road users that cause incidents, “Everyone’s Responsibility” will not change drivers’ opinion that pedestrians are mainly struck due to poor pedestrian choices and behaviour. 

Many also consider pedestrians have the “most to lose”, therefore the onus of safety is on them. These opinions are harmful and factually inaccurate, as demonstrated by analysis from years of local incident data.

Road safety messaging and development of any campaigns must focus on those most affected by dangerous driving choices, such as senior pedestrians, and target behaviour that is factually ascertained to be a significant problem for those road users.

The message of “Everyone’s responsibility” could undermine the credibility and effectiveness of any campaign, and will simply end up in finger-pointing between road users. 

A proven result-based approach should be adopted in conjunction with enforcement campaigns, as for previous successful local efforts that specifically target known offences and which clearly states the responsibility for this behaviour is with the perpetrators, not the victims. .

The Traffic Injury Research Foundation set out in detail here their suggested research-based effective approach to developing a road safety campaign. This is worth considering carefully with all stakeholders per the required approach in the road safety strategy, before finalising any campaign and messaging.

10. Enforcement

Failure to yield by drivers and crosswalk safety remains a very significant and daily concern for many, as evidenced by the incident data. 

Why are no enforcement actions identified specifically relating to crosswalk yielding, given the very many recent fatalities and severe injuries caused by drivers who failed to yield to pedestrians lawfully using a crosswalk? 

11.  Key Recommendations

1. Propose the pedestrian safety action plan is developed immediately. 
2. Develop High Injury Network mapping to orientate priority safety interventions.
3. Assess lack of safety at wider signalized intersections where vulnerable road user safety infrastructure does not currently exist.
4. Create a Road Safety Team that includes all stakeholders with decision making.
5. Ensure the Road Safety Team develop key priorities for engineering, enforcement and education, orientated by the High Injury Mapping and pedestrian safety action plan.
6. Propose the development of written policy on Right on Red permission removals and on signalized intersection traffic controls which enable vulnerable road user safety.
7. The Transportation Association of Canada has no rigid “warrant” process or fixed criteria for establishing crosswalks, therefore recommend the development of local policy on crosswalk placement that prioritises all age and ability pedestrian mobility requirements.
8. Ensure disabled and senior road users benefit from a user ability/disability based safety assessment/audit, which should be developed with cognitive experts.
9. Review current policies and decision-making against safety assessments for key road users including people with learning and physical disabilities, seniors and children. How is current policy and decision making processes meeting specific requirements for those users, for example relating to the approval of sidewalk detours? 
10. Ensure lower speed limit applications made to the Province reflect where incident data identifies there is most need – in particular downtown areas, also artery and collector roads.  Take the lead from Lockeport, Nova Scotia, and work towards a 30 km/h speed limit on all streets.
11. Review persistent issues, for example the dangerous but common placement of signage on or over sidewalks or crosswalks, which is always extremely hazardous for people with sight disabilities. Can fines for offenders be introduced in bylaws?

If you walk, cycle or use a wheelchair and are affected by road safety issues, please join HRM Safe Streets for Everyone. If your local crosswalk needs a crosswalk flag, please contact the Crosswalk Safety Society. Please remember to report issues affecting your safety to our municipal authorities using the 311 service.